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4 November 2025

South Africa's FATF Greylist Exit: A Progressive Step In The Continued Path Towards Integrity?

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Herbert Smith Freehills Kramer LLP

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On 24 October 2025, South Africa was officially removed from the Financial Action Task Force ("FATF") greylist, following almost three years of intensive reform efforts...
South Africa Finance and Banking
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On 24 October 2025, South Africa was officially removed from the Financial Action Task Force ("FATF") greylist, following almost three years of intensive reform efforts to address critical concerns identified by the FATF. South Africa was first placed on the greylist in February 2023 based on several strategic deficiencies in its anti-money laundering and counter-terrorism financing frameworks.

These shortcomings were largely attributed to institutional weaknesses arising from the period of state capture (a term used colloquially to refer to the illegitimate use of state control for corrupt and improper purposes in South Africa) which resulted in an erosion of law enforcement and regulatory bodies' capacity to detect, investigate, and successfully prosecute financial crimes. The FATF identified 22 action items that South Africa needed to address, including improving the verification and accuracy of beneficial ownership information, enhancing inter-agency coordination, and demonstrating effective enforcement of AML/CFT laws.

In response, the National Treasury along with key law enforcement agencies and regulatory bodies have adopted several reforms such as amendments to the Tax Administration Act to facilitate information sharing, the rollout of a Traveller Management System to monitor cross-border financial flows, and the introduction of beneficial ownership reporting obligations for legal entities and trusts.

While the delisting marks a significant milestone and laudable achievement, the removal from the greylist should not be viewed as panacea indicating that South Africa's financial crime problems are under control. Now more than ever, it is not the time for self-congratulation or backslapping, the focus must remain on accountability and action. As the National Treasury and other stakeholders have noted, the delisting reflects a vote of confidence but sustained vigilance and accountability will be key to preserving South Africa's financial integrity and global credibility. To achieve this, measurable outcomes should be pursued and the gap between paper and practice addressed through action such as securing the successful prosecution of serious financial crimes, asset recoveries and sanctions for transgressions of anti-financial crime laws.

In 2025 South Africa has been rocked by several high-profile corruption scandals, specifically in the Department of Health and police services, which have revealed the looting of billions of Rands from government departments.

This seems an all too familiar tale in a South African context and begs the question, “will anything be done about it?”. Staggering amounts of money have moved from government institutions, through financial institutions and ultimately into the hands of the perpetrators. Will the enhancements made during the efforts made to be removed from the greylist assist in tracing the proceeds of corruption and preventing future plundering of South Africa's public finances? If South Africa hopes to receive a positive result from the next FATF mutual evaluation, surely progress needs to be demonstrated and the responsible parties held to account.

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